North Carolina Association of Educators, Inc. v. State

The career-status law enacted by the State of North Carolina (defendant) created a tenure system for the employment of public-school teachers. Teachers earned career status after a successful probationary period and a favorable vote from the school board. The career-status law was repealed by the Current Operations and Capital Improvements Appropriations Act of 2013, which retroactively revoked the earned-career status of public-school teachers. The stated goal of the new act was to maintain the quality of public-school teachers by making it easier for the school districts to dismiss low-performing teachers. The North Carolina Association of Educators, five public-school teachers with earned-career status, and a probationary teacher (plaintiffs) filed a complaint in the trial court and argued that repeal of the career-status law violated the Contract Clause of the United States Constitution. The trial court declared the new act unconstitutional only as it applied to the teachers with earned-career status. The trial court granted a preliminary injunction to the teachers with earned-career status to prevent the state from enforcing the new act. All parties appealed the matter. The appeals court affirmed the trial court’s ruling that repeal of the career-status law violated the Contract Clause as to teachers with earned-career status. The state appealed this decision.